C5 (Germany)GDPR

C5 (Germany) covers 20% of GDPR

8 of the 40 controls in GDPR are already satisfied by evidence you collected for C5 (Germany). 32 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

20%
of the target already covered
8
controls evidenced
32
genuine gaps
0
claims rejected in review

This number is directional. It says how much of GDPR your C5 (Germany) evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

35 candidate mappings were examined and 0 were removed. Signed off 2026-08-20, review level machine verified. Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

Chapter IV - Controller and Processor6 of 16 evidenced, 10 to do
Chapter V - Transfers of Personal Data2 of 6 evidenced, 4 to do
Chapter II - Principles0 of 7 evidenced, 7 to do
Chapter III - Rights of the Data Subject0 of 11 evidenced, 11 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

C5-COM-03GDPR-Art.24argued against and upheld
Responsibility of the controller

Annual internal audit tests compliance with identified legal and regulatory requirements and tracks corrective action.

C5-COM-01GDPR-Art.24argued against and upheld
Responsibility of the controller

Requires legal and regulatory obligations and the procedures for complying with each to be documented.

C5-SP-02GDPR-Art.24argued against and upheld
Responsibility of the controller

Annual expert review of policies weighs legal change and approves revised versions before they take effect.

C5-PSS-08GDPR-Art.25argued against and upheld
Data protection by design and by default

Roles and rights concept makes least privilege and need to know the default access position.

C5-DEV-10GDPR-Art.25argued against and upheld
Data protection by design and by default

Production data must not be used inside development or test environments.

C5-OPS-24GDPR-Art.25argued against and upheld
Data protection by design and by default

Strict documented separation of customer data on shared resources limits who that data is accessible to.

C5-OPS-11GDPR-Art.25argued against and upheld
Data protection by design and by default

Metadata collection is confined to defined purposes, anonymised where possible and deleted once the purpose ends.

C5-SSO-04GDPR-Art.28argued against and upheld
Processor

Third party compliance with agreed security and legal obligations is verified through independent assurance reports.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

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